Free Answer to Complaint - District Court of Connecticut - Connecticut

Case 3:01-cv-02290-MRK

Document 26

Filed 07/21/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA, Plaintiff vs: ONE PARCEL OF PROPERTY LOCATED AT 32 MEDLEY LANE, BRANFORD, CONNECTICUT, WITH ALL APPURTENANCES AND IMPROVEMENTS THEREON, AND Defendant [CLAIMANTS: HAROLD E. VON HOFE, AND KATHLEEN J. VON HOFE] ANSWER TO VERIFIED COMPLAINT OF KATHLEEN M. VAN HOFE Now comes the defendant, Kathleen M. Van Hofe, by and through her attorney, Jonathan J. Einhorn, of New Haven, Connecticut, who respectfully answers the plaintiff's verified complaint, as follows: ANSWER: 1. Paragraphs 1, 2, 3, 4, 5, 6, 7, 9, 26, 35, 36, 37, and 38 are admitted. 2. Paragraphs 8, 33, and 39 are denied. FIRST SPECIAL DEFENSE: The defendant, Kathleen M. Van Hofe, who is the owner of an undivided one-half interest of the premises denies any knowledge of any criminal activities at 32 Medley Lane, Branford, Connecticut. JULY 21, 2004 CIVIL NO. 3:02 CV2290 (MRK)

Case 3:01-cv-02290-MRK

Document 26

Filed 07/21/2004

Page 2 of 2

SECOND SPECIAL DEFENSE This court of equity should not allow this defendant's one-half interest in the premises to be forfeited due to the criminal conduct of the other owner of the premises. THE DEFENDANT

By:____________________________ JONATHAN J. EINHORN, ESQ. 412 ORANGE STREET NEW HAVEN, CT 06511 Fed. Bar No. CT 00163 PHONE: 203-777-3777 CERTIFICATION This is to certify that a copy of the foregoing pleading was this date mailed, postage prepaid, to the following counsel and parties of record: David X. Sullivan Asst. U. S. Attorney P. O. Box 1824 New Haven, CT 06598 __________________________ JONATHAN J. EINHORN, ESQ.